Estate of Higgins v. Commissioner
United States Tax Court
Decedent's will left a life interest in the residue of his estate to his surviving spouse and the remainder interest therein (subject to the payment of taxes, administration expenses, and certain needs of the surviving spouse) to designated charities. Held, the personal representative of the estate did not make an election to have the interest treated as "qualified terminable interest property" (QTIP) under sec. 2056(b)(7), I.R.C. 1954.
1Opinion of the Court
Estate of John T. Higgins, Deceased, Manufacturers National Bank of Detroit, Personal Representative, Petitioner v. Commissioner of Internal Revenue, Respondent
Estate of Higgins v. Commissioner
Docket No. 11431-86
United States Tax Court
91 T.C. 61; 1988 U.S. Tax Ct. LEXIS 91; 91 T.C. No. 7;
July 19, 1988. July 19, 1988, Filed
Decision will be entered under Rule 155.
Decedent's will left a life interest in the residue of his estate to his surviving spouse and the remainder interest therein (subject to the payment of taxes, administration expenses, and certain needs of the surviving spouse) to…
2Cases cited15 opinions
- Humes v. United StatesSupreme Court of the United States · 1928
- Knight-Ridder Newspapers, Inc. v. United StatesCourt of Appeals for the Eleventh Circuit · 1984
- Tipps v. CommissionerUnited States Tax Court · 1980
- John H. Young and Carolyn J. Young v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1986
- Valdes v. CommissionerUnited States Tax Court · 1973
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